INFORMATION WE COLLECT
Information you provide: When you register an account, we collect some Personal Information, such as your name, title, email address, phone number, avatar and biography. In general, your name, email address, phone number and other information you choose to provide on the Service will be viewable and discoverable by other users. In some cases, where content has been shared with users outside your email domain extension, your information may be viewed by those additional users.
If you choose to use our invitation service to invite a friend to the Service, we will ask you for that person’s email address, phone number or other relevant contact details and automatically send an invitation. We shall only collect and use this information in jurisdictions where it is lawful to do so. When you agree for Foko to access your device’s contacts app, we will collect the names, phone numbers and email addresses of the people you invite to a photo or to a network. Where it is lawful to do so, Foko stores this information to send an invitation via email or SMS, to register your friend if your invitation is accepted. We may also receive Personal Information (for example, your email address or phone number) through other users, for example if they have tried to share something with you or tried to invite you to Foko.
Content: You also provide information in Content you post to the Service. In general, the Content you provide will be viewable and discoverable by other users. In some cases, where content has been shared with users outside your email domain extension, your information may be viewed by those additional users. Foko can, but has no obligation, to monitor the Content you post on the Service. Geo-Location Information: Content that you upload or share in Foko may contain recorded location information. Location data does not collect or share any personally identifiable information about you. Location data may be used in conjunction with personally identifiable information.
Device Identifiers: When you access the Service by or through a mobile device, we may access, collect, monitor and/or remotely store one or more “device identifiers”. Device identifiers allow us to uniquely identify your device and are used to enhance the Service (including sending updates and information from the Service). A device identifier does not collect or share any personally identifiable information about you. A device identifier may be used in conjunction with personally identifiable information.
Analytics: When you access the Service on our website, we may collect information (using third party services) using logging and cookies which can sometimes be correlated with Personal Information. We use this information to monitor and analyze use and interest in the Service. As of the date of this policy, we use Google Analytics for this work.
Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
HOW WE USE INFORMATION
Foko uses information that it collects for the purpose of fulfilling our contractual obligations to you under our Terms of Service, in furtherance of our legitimate interests in operating our Services, Websites and business and/or where you have consented to such usage . More specifically, Foko uses Personal Information:
To provide, update, maintain and protect our Services, Websites and business. This includes use of Personal Information to support delivery of the Services under our Terms of Service, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request. We may use your email address or phone number to send you Service-related notices (including any notices required by law, in lieu of communication by postal mail). If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.
As required by applicable law, legal process or regulation.
To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Personal Information to respond.
To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Foko. These are marketing messages so you can control whether you receive them.
For billing, account management and other administrative matters. Foko may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
To investigate and help prevent security issues and abuse.
For marketing purposes. We may also use your contact information to send you marketing messages. If you are in the EEA we will only to do if you have opted in to receive such communications. If you don’t want to receive these messages, you can opt out by following the instructions in the message.
HOW WE SHARE YOUR INFORMATION
Your Use: We will display the information you provide on your profile page and elsewhere on the Service. In general, the information and Content you provide will be viewable and discoverable by other users or people invited to the service. In some cases, where content has been shared with users outside your email domain extension, your information may be viewed by those additional users. Any information you choose to provide should reflect how much you want others to know about you. You can review and revise your name, title, biography and avatar at any time.
Service Providers, Business Partners and Others: We may from time to time use the services of affiliates, subsidiaries and unrelated service providers in the operation of the Service, and may disclose personal information to them in the course of our use of their services. For example, we may use the services of third-party hosting companies to host the operation of the Site. This may involve the hosting of data, including personal information, on servers operated by those hosting companies. We encourage you to review these other privacy statements. We ensure that we have appropriate safeguards in place if we transfer Personal Information originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law, including without limitation ensuring that the Service Provider is EU-Us Privacy Shield compliant or requiring them to enter into the European Union Standard Contractual Clauses.
Compliance with Laws and Law Enforcement Requests; Protection of Foko’s Rights: Foko may disclose your personal information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Foko’s rights or property.
Non-Personally Identifiable Information: We may disclose your non-private, aggregated, or otherwise non-personally identifiable information, such as anonymous usage data, platform types, etc., with interested third parties to help them understand the usage patterns for certain Foko Services.
HOW WE PROTECT YOUR INFORMATION
The security of your information is important to us. Foko enforces Roles Based Security to limit user access to data. We use trusted third party services for data security, system security, back-ups, and disaster recovery.
INTERNATIONAL DATA TRANSFER
LINKS TO OTHER WEB SITES
IDENTIFYING THE DATA CONTROLLER AND PROCESSOR
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Foko is the controller of information which Foko requests or collects for the purposes of maintaining the Service. Foko’s customers are the controller of Personal Information which they enter into the Service which is not requested by Foko. Foko’s Data Processing Addendum applies to the processing of any Customer Data to which the General Data Protection Regulation (2016/679) applies.
Under certain circumstances, you have rights under data protection laws in relation to your personal information. You may have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the contact details below.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
153A Promenade du Portage, Suite 200
Gatineau QC, J8X 2K4
QUESTIONS? EMAIL US AT CUSTOMER@FOKORETAIL.COM